The doctrine of priest–penitent privilege does not apply in England. However, before the Reformation, England was a Roman Catholic country and the Seal of the Confessional had great authority in the English courts. Anglo-Saxon England In Anglo-Saxon England, there several laws concerning confession. The laws of Edward the Elder, son of Alfred the Great, enjoin: This injunction is repeated in the forty-fourth of the secular laws of King Canute. These laws are prefaced thus: "This then is the secular law which by the counsel of my witan I will that it be observed all over England". The laws of King Ethelred the Unready declare (V, 22): The very close connexion between the religion of the Anglo-Saxons and their laws, many of which are purely ordinances of religious observance enacted by the state, the repeated recognition of the supreme jurisdiction of the Pope, and the various instances of the application in the Church in England of the laws of the Church in general lead to the opinion that the ecclesiastical law of the secrecy of confession was recognized by the law of the land in Anglo-Saxon England. After the Norman Conquest In the period between the Norman Conquest and the Reformation the law of the Church in general, as to the inviolability of the seal of confession, is stringently enjoined by English councils. The Council of Durham (1220) declared as follows: The Provincial Council of Oxford, held in 1222, contains a similar canon, in which degradation is prescribed for any breach of the seal. The law, as laid down by the 21st canon of the Lateran Council, is also declared in the Acts of the Synod of Exeter in 1287 (Spelman, Concilia, II, 357). The fact that the laws of the Church were so emphatic on the subject, coupled with the fact that the Church was then the Church of the nation, affords good ground for inferring that the secular courts recognized the seal. The recognition of it would not have rested on any principle of immunity from disclosure of confidential communications made to clergymen. It would have rested on the fact that confession was a sacrament, on the fact of that necessity for it which the doctrine of the Church laid down, on the fact of the practice of it by both king and people, and on the fact that the practice was wholly a matter of spiritual discipline and